Courts on AI / Fabricated or misquoted citations

Brandon Rulund Akins v. Tashi Latwon Ratliff

United States District Court for the Middle District of North Carolina · Federal district courts · NC · 2026-04-28 · No. 1:25cv712 · report and recommendation

Fabricated or misquoted citations

The Middle District of North Carolina on 2026-04-28 warned the self-represented plaintiff to verify legal authorities and cautioned that future hallucinated or nonexistent citations may bring sanctions in Brandon Rulund Akins v. Tashi Latwon Ratliff, et al. The self-represented plaintiff filed a submission with nine fabricated case citations.

Disposition: The application was granted for purposes of recommending dismissal, ancillary motions were resolved or recommended moot, and Akins was warned about future inaccurate filings.
Recorded conduct: Akins’s pro se filings contained non-existent or wholly inapplicable authorities, including repeated non-existent citations to Calderon, Estate of McCall, Harris, Bowser, and R.S. v. Board of Directors. The court warned future fabrications may be sanctioned. — outcome: warning; actor: litigant in person
Canonical record: Incident tracker entry — verified outcome, regulator disposition and related rules

What the court wrote

Verbatim from the court's document (public domain). Ellipses mark omitted text; nothing is paraphrased.

Scharf, No. 3:25cv1015, 2026 WL 642917, at *2 (W. D. N. C. Feb. 25, 2026); see also id. (“Even a cursory Google search would [have] reveal[ed] that these cases do not exist [as cited]. ”). More pointedly, Plaintiff’s submissions foreground an issue that “[c]ourts across the country are grappling with,” In re Nwaubani, No. 25-9517, 2026 WL 687194, at *3 (4th Cir. Mar. 11, 2026), in that citations such as Plaintiff’s to “nonexistent cases . . . are the frequent posterchild” for “the use of generative [artificial intelligence] in materials submitted to the court,” id.; see also Kruglyak v. Home Depot U.

Authorities cited in the passage: Kruglyak v. Home Depot U.

Court document: govinfo.gov
Public copy first read: damiencharlotin.com
Read: 2026-09-08 · court's own copy read
Found via: charlotin-hallucinations-db
Notes: Official copy located 2026-09-08 via govinfo; quoted passage confirmed in the official document. Re-coded from the document 2026-09-08 (independent second read).

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